Like all other states, Connecticut regulates alcoholic liquor on the federal, state, and even local levels.

 The vast majority of Connecticut's more than 7,000 permit holders strive to comply with those laws and regulations. Restaurants, bars, package stores, and grocery stores operate in a safe and professional manner, resulting in an environment where customers and patrons can enjoy themselves with family and friends and employees can work and thrive in a work setting that provides for their well-being.

 However, there are instances when a premise is operated in such a manner that it presents an immediate danger to its patrons and customers, requiring swift action by the Commissioner of the Department of Consumer Protection ("Commissioner"). Under CT law, if the department "finds that public health, safety or welfare imperatively requires emergency action, and incorporates a finding to that effect", the Commissioner may order a summary suspension of a liquor permit pending proceedings for revocation or other action.

According to the department's public website, five liquor permit premises were the subject of a summary suspension in the calendar year 2024. Four suspended premises were on-premises permit holders (restaurants, bars with a café permit), and the fifth was a package store.

In each instance, that jurisdiction's chief law enforcement officer notified the department in writing of the incident that prompted the request for an immediate suspension (without a due process hearing). In each of the five requests, there was a history of past instances of wrongful behaviors by the premises' management and/or staff. In the matters involving the bars and restaurants, the incidents involved the use of firearms or knife stabbings, resulting in death or injury to patrons, and a lack of management controls over the permit premises. In the package store incident, it was alleged that large-scale drug trafficking and illegal gambling crimes, together with associated Mexican gang activity, were occurring within the store by its employees and manager(s).

In each instance, the local chief or designated command officer notified the department within a day of the incident and provided investigative details demonstrating the need for immediate action.

The summary suspension process can be an effective tool for providing a short-term or temporary remedy for lapses in compliance that cannot reasonably or adequately be resolved in a timely manner by other means. It is used sparingly in Connecticut because it is recognized that a permit holder's due process rights will "kick in" only after the premises are shut down and not allowed to reopen until the matter is resolved.

A review of the summary suspension orders for 2024 reveals a common theme: permittees have a responsibility to protect public health and safety.

What happens after the summary suspension is ordered, and how are the matters resolved?

Stay tuned for the next essay of Speaking Easy.

If you have any questions or would like more information on this topic or any liquor-related matter, reach out to The JS Consulting Group.